Case Digest (G.R. No. L-21475)
Facts:
The case of Amancio Balite vs. People of the Philippines (G.R. No. L-21475) revolves around a criminal complaint for grave oral defamation filed by Delfin Mercader against Amancio Balite. The events leading to the case began in December 1958 when the Democratic Labor Association declared a strike against the Cebu Stevedoring Company. During this period, Mercader, the union president, was offered P10,000 by Richard Corominas & Co., a copra exporter affected by the strike, to aid the union and facilitate a settlement. Balite was present during this offer and later proposed that the money be given solely to the union officers, which was met with strong opposition from the members. Following this, Balite threatened to destroy the union and to expose Mercader.
In May 1959, Balite publicly accused Mercader of corruption while speaking to members of the Marine Officers Guild. He claimed that Mercader had swindled union funds and received bribes from both the copr...
Case Digest (G.R. No. L-21475)
Facts:
Labor Dispute and Union Meeting:
In December 1958, the Democratic Labor Association declared a strike against the Cebu Stevedoring Company. Delfin Mercader, the union president, was offered P10,000 by Richard Corominas & Co. to aid the union and settle the labor dispute. Amancio Balite, the petitioner, was present when the offer was made. At a union meeting, it was decided to distribute the money among all members, but Balite proposed that only the officers receive the amount. His proposal was rejected, leading to his expulsion from the union.Defamatory Statements:
On May 21, 1959, Balite met members of the Marine Officers Guild at the Cebu City waterfront. In the presence of several individuals, Balite accused Mercader of selling the union, swindling union funds, receiving bribes (P10,000 from Richard Corominas & Co. and P6,000 from Cebu Stevedoring Company), engaging in racketeering, and enriching himself with capitalists. These statements were made in the Cebu Visayan dialect and were translated into English.Legal Consequences:
Mercader, who was the legal counsel of the Marine Officers Guild at the time, was subsequently eased out of his position due to the defamatory statements. Mercader filed a criminal complaint for grave oral defamation against Balite, which was investigated by the City Fiscal’s Office. The complaint was filed in the Cebu City Court, and Balite was found guilty and sentenced to 4 months and 1 day of arresto mayor, with a civil indemnity of P5,000.Appeal and Modification:
On appeal, the Court of Appeals modified the penalty to an indeterminate sentence of 4 months and 1 day of arresto mayor (minimum) to 1 year and 8 months of prision correccional (maximum). Balite challenged the jurisdiction of the Cebu City Court, the nature of the defamation (grave vs. slight), and the prescription of the crime.
Issue:
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Ruling:
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Ratio:
Jurisdiction:
Criminal actions for defamation can be initiated by either a complaint or an information. The fiscal’s adoption of the complaint filed by the offended party satisfies the statutory requirement for initiating the criminal proceeding. The expanded jurisdiction of city courts under Republic Act 2613 also applies, allowing them to hear cases with penalties of up to six years imprisonment.Nature of Defamation:
The determination of whether defamation is grave or slight depends on the seriousness and insulting nature of the statements, as well as the circumstances surrounding the case. Imputations of serious crimes, such as estafa and racketeering, constitute grave oral defamation.Prescription:
The prescriptive period for slight oral defamation is two months, but for grave oral defamation, it is longer. The complaint was filed within the applicable period for grave defamation.Condonation by the Offended Party:
Pardon or condonation by the offended party does not extinguish criminal liability, except in specific crimes enumerated in Article 344 of the Revised Penal Code. However, it waives the civil liability arising from the offense.Penalty Correction:
The penalty for grave oral defamation must conform to the Revised Penal Code’s provisions. The minimum penalty under the indeterminate sentence law should be within the range next lower in degree to the prescribed penalty.